On December 10, 2020, the FCC released an E-rate Invoice Order granting applicants and service providers 120 days after the receipt of an RFCDL, or the successful appeal of a previously denied or reduced funding request, to file any associated invoices.

In addition, the Order retroactively deals with outstanding invoice deadline issues by providing the following recourse:

• Applicants and service providers who had been unable to file invoices as a result of late-received RFCDLs and had filed a timely FCC waiver request (regardless of whether or not they had received a one-time, 120-day invoice deadline extension) will receive the same 120-day window to file invoices.
• Applicants and service providers affected by similar late-RFCDL invoice problems and who had not previously filed an FCC waiver are given a one-time opportunity to file an FCC waiver. Such waivers must be filed within 60 days following the publication of the Order in the Federal Register and must show good cause as to why these waivers were not initially filed in a timely manner.

The FCC’s Order includes a reminder that the rule change applies only to post-commitment requests or appeal decisions that result in an RFCDL and "applicants or service providers appealing partially approved funding requests should submit invoices for the partial funding before the original invoice deadline expires because USAC will not provide additional time to invoice if the appeal is denied.”

Download FCC 20-178 PDF